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Summary of submissions
Comments on key consultation issues
The goal: how ambitious?
A total of 853 written submissions were received from a wide range of individuals and organisations. Many were from private individuals, but they also came from city, district, and regional councils, and from road safety consultants, traffic engineers, roading contractors, road transport operators, students, transport research organisations, psychologists, the motor vehicle industry, motorcyclists, cyclist groups, pedestrians, motoring clubs, the health sector, groups representing older people, government agencies, driving schools, community boards and groups, child safety groups, the alcohol industry, and many others.
About right
Just over half of all respondents agreed with the goal of achieving a level of safety in 2010 equivalent to that now achieved by the safest countries in the world. Many felt that this was ambitious but that anything less would be unacceptable and we should always be aiming for and encouraging even better achievement and standards.
The need to support an analytically-driven goal with an overarching vision was also commented on. The Swedish model of "Vision Zero" and concepts such as "safety culture" were mentioned in this regard.
Local Government New Zealand supported the goal, but commented that it would be a challenge ensuring that New Zealanders were committed to it. Several local authorities considered the goal to be ambitious but achievable, considering the road toll reductions already achieved in New Zealand and what other countries had achieved.
The New Plymouth District Council, South Taranaki District Council, Taranaki Regional Council and Northland Regional Council all supported the goal provided that appropriate funding was committed.
The Local Authority Traffic Institute of New Zealand (TRAFINZ) submitted that the 10-year goal should be part of a longer-term vision of planning for zero road deaths. The Dunedin City Council was in agreement with this suggestion. The Wellington City Council considered that it was unacceptable to set a goal for road deaths, but accepted that would be unrealistic to set a Vision Zero goal for 2010. It also saw the goal of halving the road toll by 2010 as being a realistic step towards a long-term goal of no road deaths.
Road Safe Nelson Bays said that it envied the "Vision Zero" approach adopted by Sweden, but did not believe New Zealand had the population or tax base to support it. They considered it would be better to have a realistic goal than a visionary or ideal one that would be impossible to meet.
Transit New Zealand supported the proposed 2010 Strategy as the next major step in reducing the New Zealand road toll. It considered that the Strategy would represent a significant advance over the next 10 years and that it would build upon road safety activities already under way. However, Transit also expressed some concern that the other countries whose current level of safety we would be trying to match were not comparable with New Zealand (in terms of average distances travelled, climate, and the condition of their roads).
Transfund New Zealand commented that the proposed goal was very challenging and would require commitment from all the core agencies. Transfund itself undertook to continue to play a strong role in co-ordinated efforts to reduce the road toll. Transfund also had concerns about the international comparisons and suggested expressing the goal in terms of crash rates per unit of travel. The Road Transport Forum also considered that it was important to use the safest countries that were directly comparable with New Zealand.
Beca Carter Hollings and Ferner supported the goal, but questioned whether the safest countries might have a level of enforcement unacceptable to New Zealanders, whether New Zealand might be unable to reach the required standard of engineering within ten years, and whether the high road toll reductions of the past 13 years might be unsustainable over the next ten.
Federated Farmers reported mixed views among its members about whether the goal was realistic, especially if significant amounts were to be spent in trying to achieve it, or significant restrictions were to be imposed. However, it supported the goal with the proviso that the safest countries were truly comparable with New Zealand.
A number of local authorities were also concerned about New Zealand's comparability with other countries. Among these were the Gore, Waikato and Stratford District Councils, and the Napier City Council.
More safety
About 25% of respondents considered that the target of being equivalent in 2010 to the best countries' performance now, was not ambitious enough and not likely to inspire the public. Some felt that we should aim to be at the same level as the best countries in 2010, and even in one case that we could aim to be doing as well as Australia in 3 years; others considered that Vision Zero was a more inspiring or more moral goal and that acceptance of any road deaths at all was too much of a compromise.
The Cycling Advocates' Network (CAN) supported "Vision Zero" and believed that a vision was more important than a goal. Developing a better safety culture should be one of the Strategy's goals and safety itself should be defined. CAN's definition of safety was stated as when every road user takes responsibility for avoiding crashes, and mode choice is not influenced by perception of risk.
The Wairarapa Ambulance Service, among others, supported a zero tolerance goal, saying that a mere percentage decrease trivialised the importance of the initiative.
Crown Public Health Ltd submitted that the goal should be more ambitious and should be expressed in terms of vehicle kilometres travelled.
Less safety
Fewer than 3% of respondents thought the goal was too ambitious. The AA Driver Education Foundation considered that the goal of reducing the road toll by 45% in ten years was unrealistic and unachievable, but supported in principle the setting of realistic goals. The Tauranga and Western Bay of Plenty Road Safety Committee and the Wanganui District Council both commented that the goal needed to be achievable: for example, to aim for "a steady reduction" or to match Australia's current road safety record. Other individuals commented about the need to be realistic about costs and the unacceptability of the increased enforcement and tighter regulation that would be necessary to achieve the goal.
A different goal
A total of 17% of respondents supported a goal different from that proposed. Comments included the need to create enthusiasm among average New Zealanders about the goal, comparing ourselves with similar countries in terms of GDP and driving conditions, and accepting that 100% safety was impossible. One submission suggested aiming for overall road safety to be on a par with the safety level of public transport systems.
Environment Southland doubted whether the people of New Zealand were prepared to pay significantly more to achieve such a goal, and suggested the goal should be set after establishing how much the community was willing to pay.
Preferred option for achieving the goal
This question asked which emphasis was preferred: enforcement of road user behaviour, engineering of a safer road environment, or a mix of the two. Over half supported the mixed option, usually with education added to the mix. Around a quarter supported options other than those proposed in the documents.
Enforcement
A small number of the 40 respondents who favoured the enforcement option wanted to leave the speed limit at 100 km/h. Most others appeared to accept the proposed lower limit. Some also believed that other enforcement interventions should be implemented even though they would be unpopular. Others commented that New Zealand already had very good roads.
CAN wished to see as many as possible of the enforcement measures implemented, as it considered that the disadvantages of the engineering option to cyclists (e.g. increased risk taking by drivers) had not been adequately considered. Others considered the enforcement option safer for cyclists and pedestrians, unless engineering measures took into account the needs of these groups better than they did now.
Several local authorities (Environment Southland, Kaipara and Opotiki District Councils) and individuals supported the enforcement option on the grounds of cost.
Engineering
Those who supported the engineering option considered that it offered more long-term or permanent benefits despite the higher initial cost. Some commented that money needed to be spent on the roads to improve their condition.
The Wellington City Council supported engineering because of the difficulty in getting public support for the enforcement measures. It also commented that the benefits were more long term and affected drivers less adversely (apart from the cost).
The Pavement and Bitumen Contractors' Association also doubted that there would be public support for enforcement measures, and drew attention to the other benefits of engineering such as reduced travel times and vehicle operating costs.
The New Zealand Contractors' Federation also considered that engineering offered a more sustained effect, and commented that enforcement interventions tended to target the average driver rather than the at-risk driver, although they acknowledged and supporting the role of enforcement.
Road Safety Southland commented that engineering provision for other road users, such as skateboarders, cyclists and scooters, would reduce traffic congestion and improve health and the environment. They considered that enforcement would have a limited and short-term effect.
Mix
The majority of respondents (54%) favoured a mix of interventions. Many wanted education as a larger part of the mix than was apparent in the strategy documents. Some felt that driver education might make expensive road engineering unnecessary, while others considered that, without driver education we would fail to get the full benefit of better roads. Education might also help the public to understand why enforcement measures that seemed draconian were necessary. Many considered that training in driving techniques was a necessary part of the mix.
One individual thought that the mixed option could be renamed the "social awareness" or "social emphasis" option. This option was considered by many to be a good compromise between high costs and restrictive interventions, and between short- term and long-term benefits. Several respondents wanted to change the mix to more emphasis on either enforcement or engineering than was proposed.
The Energy Efficiency and Conservation Authority considered that measures to reduce the amount of unnecessary or unproductive travel should be included in the mix, to lower the road safety risk and also reduce energy use. It also wanted more emphasis on sustainable, energy-efficient and physically-active modes of transport.
The Auckland Regional Council stressed the need for co-operation and co-ordination between agencies at national, regional and local levels, as did the Waitakere City Council.
Federated Farmers advocated more effective and consistent enforcement of the current standards, rather than tightening the standards. They also supported an increase in roading expenditure, with cost/benefit analyses taking account of the network-wide effects of interventions. The Otorohanga District Council supported stricter enforcement of the current legislation before introducing more stringent measures.
The Marlborough, Gore and Southland District Councils, Hamilton, Napier, Porirua and Hutt City Councils, and the Northland, Auckland and Taranaki Regional Councils all wanted education to be a significant part of the mix, as did the Wellington and North Shore branches of Age Concern, Barnardo's New Zealand, the Hurunui Road Safety Co-ordinating Committee, the Injury Prevention Research Unit of Otago University, the National Council of Women, the Automobile Association, and Safekids, among others.
The Nelson/Marlborough Health Service supported a mix of interventions, but considered that any additional money should be spent on engineering because it provided the best long-term effect and did not rely on people to modify their behaviour.
The AA's membership supported the options in these proportions: 67% mixed; 13% engineering; and 20% enforcement. The AA supported an expanded road construction programme to gain safety benefits. It believed that motorists would support an increased funding level for road safety linked to a mixed option provided that the Government was committed to using some of the non-roading excise tax on petrol towards these initiatives, that funds were 'ring fenced' and directed only to safety initiatives, and that the specific safety initiatives were identified and the required funding accurately specified. The AA wished to be involved in the decision- making process as to how the funds were allocated to the safety initiatives.
The Road Transport Forum considered that asking the public to select one of the three options was simplistic. A mix of initiatives was necessary, but each measure should be considered on its merits and a realistic mix of policy options chosen. The RTF was strongly of the view that roading expenditure must be increased. TERNZ Ltd and the Road Safety Research Group of Waikato University also submitted that the proposed approach was simplistic, and that a more integrated approach, including driver factors, with improved education, licensing and research initiatives, was needed.
TRAFINZ supported the mixed option as being the most likely to achieve results and to be implemented. It was essential that engineering focus on safety rather than capacity enhancement so the Strategy should be consistent with encouraging reductions in traffic growth.
Transfund considered that cost effectiveness should be the main criterion for selecting the final combination of measures. Some enforcement measures that were currently politically unacceptable might become acceptable as attitudes changed. Enforcement programmes were relatively easily tailored to risk, whereas engineering measures were guarding against random and unpredictable events with less certainty of a result. Transit New Zealand also wanted a cost-effectiveness test and more targeting of enforcement and education initiatives to specific at-risk groups.
The Wairoa District Council commented that the mixed option was just a watered down version of the engineering option.
The Independent Motor Vehicle Dealers' Association believed that the enforcement component should have an educational rather than a punitive emphasis, to encourage voluntary compliance and a greater understanding of the benefits to the individual and society.
The Coalition to Reduce Drinking and Driving (CREDD) commented that, although the enforcement option appeared to provide the best cost/benefit return, the mixed option fitted philosophically with a 'vision zero' approach and introduced an ethical dimension whereby road designers, engineers, and enforcement agencies were required to take responsibility for safety within the roading system. They also considered that motorists would be more likely to accept tougher enforcement if there was a payback of better-engineered roads.
Marlborough Health Promotion supported a dynamic mix that could be adjusted over the ten-year period depending on what was shown by evaluations. Initially there should be a bias towards engineering to bring the roads up to a minimum standard.
Other
Of the 68 submissions that preferred options other than those proposed, most submitted that driver education should be the main focus or that it should be used in combination with enforcement or engineering.
Other options also included giving vehicle and pedestrian conspicuity a high priority, improving the road environment for pedestrians and cyclists and encouraging these modes, enforcing current measures rather than tightening them, and road traffic reduction measures (e.g. increasing use of rail and other public transport).
The Cycling Strategy Foundation Project considered it inadequate and methodologically indefensible to omit education from the choice of options. They called for a three-cornered rather than a linear structure. The National Pedestrian Project recommended that the Ministry of Transport take a lead role on pedestrian issues, and establish the obligations and standards for key organisations to protect the "walkability" of the New Zealand environment. Health Waikato Community Health Injury Prevention Team submitted that better public transport systems, along with education to develop a public transport culture, would reduce the need for costly road construction and that in the long term an integrated transport system would be more economically sustainable.
Preparedness to pay
The consultation document asked for comments on the relative costs of the different options: the most expensive option of roading improvements, or the less expensive option of tougher law enforcement. It also asked whether the estimated cost increases would be acceptable to road users, and whether they changed people's views about which would be the best programme option.
A total of 188 people responded to this question. Of these, 37% said maybe (or gave answers that were neither yes nor no); 18% said no; 34% said yes; and 11% proposed some other option.
Maybe
A recurrent comment was that motorists were already paying through petrol excise, road user charges and licensing fees, but this transport tax had gone into the Crown Account instead of being used for the benefit of road users. There was a widespread opinion that more of the revenue obtained from road users should be used for road safety.
Local Government New Zealand submitted that it was critical that any new funds collected were tagged for road safety, and suggested that a higher proportion of enforcement fines and penalties be spent on road safety initiatives.
The Auckland Regional Council stated that investing more in safety initiatives was both warranted and supported by the community — however, funding sources needed clarification. The Council wanted an assurance that the funding would not be at the expense of other transport initiatives like public transport, that each measure would be funded for safety rather than efficiency or capacity reasons, and that the issue of local authority contributions to funding would be addressed.
Federated Farmers disagreed with the system of using local authority rates to pay for roads because rates on property had no relationship to use of the roading system. They submitted that safety costs should be apportioned to the appropriate vehicle types, and that rates should be removed as a funding source by using fuel excise revenues instead.
The Porirua City Council expressed the view of a number of local authorities that the issue of whether the contribution from rates would increase needed clarification. They said that this was discussed during the presentations, but was not made clear in the documents. Manukau City Council also expressed concern that the implications for rates had not been analysed if roads were still to be funded on the same basis.
The Automobile Association's view was that motorists will be willing to accept some increase in costs to fund improved road safety, but only if the Government demonstrated its willingness to share the burden by committing to it a proportion of the non-roading revenue currently taken from motorists. Also, the safety initiatives and their funding should be clearly identified and the AA should be involved in decisions about how the funds were allocated. The AA said that its polling confirmed that motorists expected there would be an adequate investment in their safety through a contribution by the Government from the taxes they already paid. It said that there was an almost unanimous view among motorists that a proportion of the funds currently siphoned off to other areas of government expenditure should be redirected towards safety initiatives.
Opus International Consultants commented that, if the additional improvements to engineering were funded nationally rather than from local authorities, it would be difficult to separate these from the normal Transfund subsidies. So, funding should meet the same rules to highlight differences between roading networks for the sake of equity. If targeting resulted in more funding to high-volume roads, there could be a perception of inequity by some road users, including cyclists, pedestrians and public transport advocates. Opus considered that extra charges other than petrol taxes could lead to more unlicensed driving and unregistered vehicles. A significant proportion of the extra funding should come from general taxation, in recognition of the social cost savings. Wide public acceptance and community buy-in were most important.
The Northland Regional Council asked whether future savings in social costs would be passed on by gradually reducing the levies on petrol, etc.
The Road Transport Forum stated that commercial transport should meet only the costs it imposed, and that there was evidence that New Zealand's charges on heavy vehicles were already grossly excessive by world standards.
Prepared to pay
About 34% of those who commented on this issue said they were prepared to pay the additional costs of the proposed strategy options. Some considered that the costs should be borne by the whole of society, not just motorists. One commented that a petrol increase would not matter, as shown when the price went up recently. As with the "maybe" comments, there was a general theme that taxes collected from road users should be spent on the roads. Safe Waitakere drew attention to the significant consequences for New Zealanders of road-related injuries and fatalities, and recommended that loss of life, loss of quality of life, pain, suffering and other intangible costs be taken into account when determining expected benefits.
Not prepared to pay
Most of the replies in this section said that they would be unwilling to pay anything over and above the current taxes on motorists, which should be used on the roads rather than directed to the Crown Account.
Age Concern North Shore was concerned that any increases in the costs of transport would impact on the mobility and social isolation of people on fixed incomes and benefits. One submission made the point that most people did not think of themselves as being at risk, and hence were reluctant to pay.
Other comments on paying
Once again, the majority of respondents commented that current taxes on petrol, RUC, etc. should all be directed towards roading or road safety. A small number of submissions commented that:
- the savings in social costs brought about by increased safety would pay some or all of the costs of implementing the strategy;
- traffic fines should be directed to road safety
- the money for the advertising programme should be used for roading improvements instead;
- road tolls should be used to fund the strategy.
Targets
The consultation document proposed four types of targets, and asked whether people agreed with them, and whether there were any issues they wished to raise about developing the targets or the activities that might be necessary to meet them.
The four types of targets proposed were:
- Numbers of fatalities and serious injuries (by local government region and road user group
- Social cost
- Targets related to speed, alcohol, restraints, roading and vehicle standards
- Safety activities (monitoring the work programme).
A total of 118 submissions responded to this question, of which more than half supported the proposed targets. Some respondents did not support the proposed targets, either in full or in part, and some proposed other targets. In some cases it was difficult to categorise the responses on targets because of different interpretations.
Support targets
Among this group of respondents there was general support for regional and user- group targets as a means of encouraging ownership at regional and community levels. The Southland District Council made the point that ownership was important if the problem was to be solved at local level, even if the numbers were statistically insignificant. They did not agree that the user-group targets be encapsulated in the targets set for the general public. Part of the ownership issue was the setting of targets that groups in the community could identify with, for example the young, the old, ethnic groups, males, and females.
The Wellington Regional Council supported the targets, but wanted additional ones for motorcyclists and drivers under 25. It considered that national targets for reducing serious injuries should be adopted.
Federated Farmers wished to see targets added for the deaths and injuries of rural people on rural roads.
The Eastern Bay Road Safety Committee supported regional targets, but suggested that road-user targets would need to be seen as meaningful by the community, and not just used for data collection. They support targets for crash numbers rather than fatalities.
The Gisborne District Council considered that high-risk regions with large networks and low populations would need extra assistance to achieve their targets.
The Hutt City Council, Local Government New Zealand, Nelson Marlborough Health Services, 3M New Zealand Ltd, Safe Waitakere, Safekids, and the National Pedestrian Project all wanted attention to be given to pedestrian and other vulnerable road-user targets. The National Pedestrian Project's was one of several submissions concerned about the need to set appropriate targets for pedestrian safety.
Beca Carter asked who would be accountable if the targets are not reached.
Opus International Consultants considered that each agency should report annually to the NRSAG on targets, to review progress and consider any changes. The stakeholders and their targets should be made known to the community, and performance reported regularly. The Marlborough Road Safety Community Group also had this view.
The Pavement and Bitumen Contractors' Association submitted that all targets should be clearly defined and their method of measurement clarified and validated.
TRAFINZ and the Wellington City Council both considered that there was a case for targets at road-controlling authority rather than a regional level, and that these should be negotiated between the RCA, the Police and the LTSA, and funded accordingly.
Environment Southland was concerned that risky roads with a high cost density would be targeted on economic grounds.
MAF Policy however, supported working with the 14 regional areas rather than with the 74 local authorities and Transit New Zealand.
Other
Several respondents suggested different kinds of targets, such as for driving standards or driver behaviour, driver training, numbers of crashes rather than fatalities and injuries, traffic-calmed streets, and the provision and use of public transport.
One expressed concern that the targets were set in relation to an ill-defined goal.
The Hamilton City Council commented that road crashes should arouse similar concern to air and rail crashes, for which no level of casualties was regarded as acceptable. The targets should only be seen in the context of a longer-term 'Vision Zero'.
The Masterton District Council agreed that a zero road toll should be the ideal goal, but that targets must be realistic. There was a case for achievable targets to be disaggregated by geographical area or road classification. If we were to adopt Australian targets we would have to be satisfied that our road conditions were comparable to theirs.
Barnardo's, the Plunket Society, Safekids, Te Wakahuia Manawatu Trust and the Nelson Marlborough Health Services wanted specific targets for children's safety.
The Public Health Directorate of the Ministry of Health commented that the final list of strategic options did not sufficiently address the safety issues of vulnerable road users (children, pedestrians, cyclists, runners, motor-cyclists, older people, and people with disabilities) and regional and local characteristics.
The Injury Prevention Research Unit at Otago University recommended improvements in data collection, including indicators of long-term and permanent disablement, and data on Maori to support the monitoring of targets. It also supported targets for young people. The National Council of YMCAs of New Zealand recommended targets for young males.
The New Zealand Cycling Strategy Foundation Project submitted that 2010 cycling targets were of limited usefulness because of the inadequacy of the data. CAN wished to see a target measure adopted for cycling that was expressed as a rate, preferably as crashes per hours cycled. General targets should not be given in both absolute numbers and rates for various units. If exposure rates changed the targets would become meaningless, as it might not be possible to achieve them all. Cycle outcomes should be expressed in terms of a rate rather than absolute numbers. CAN also recommended that, because more cycling brought more safety for each cyclist, a target for increased cycling should be included. The strategy needed targets for increasing the proportion of children cycling and walking to school, in order to capture the health benefits of active forms of transport and to reduce the risks imposed by school trips made by car. Targets should be set for proportions of traffic calmed streets as well as reduced rates of injury. The strategy needed to explicitly address the lack of cycling data.
The Otaki Cycling Environment and Access Network also submitted that there should be targets for increases in the numbers of children cycling and walking to school, and for the number of schools with Safe Routes to School schemes in place by 2010. There should also be a target for a general increase in cycling, and cycling targets should be expressed in terms of hours cycled rather than hospital admissions.
Willingness to help
This question asked people what contribution they could make towards the successful implementation of the strategy. Around 90 submissions responded to this question, most of which were prepared to help or support the strategy in some way. Many individuals offered to support the strategy on a personal level, while a few offered professional expertise in specialised areas.
A number of local authorities saw their contribution as being a continuation or an extension of their existing road safety work, and some acknowledged the importance of working in partnership with central government agencies. The Porirua City Council was concerned that its involvement should not necessitate an increase in rates beyond the level of inflation, while the Manukau City Council considered that road-controlling authorities would need to be provided with the necessary tools in the form of legislative, institutional and funding arrangements in order to address the road safety issues on their networks. The Central Hawke's Bay District Council commented that, as a road-controlling authority it would have responsibility for implementing safety management systems and safety audits. The Otorohanga District Council considered that road safety education was a central government responsibility but it would continue to support a road safety co-ordinator as long as this showed benefits to local residents.
A range of community groups and local road safety committees expressed their commitment to supporting, promoting and working within a road safety strategy. Roadsafe Nelson Bays stated that its group would contribute "limitless will and drive" even if cash was limited.
The Automobile Association offered to participate fully and positively in all stages of the strategy's development, and saw itself as a conduit for information between motorists and the Government.
Opus International Consultants stated that it wanted to continue to be involved with road safety research. Other companies, including Beca Carter Hollings and Ferner and 3M New Zealand Ltd offered their particular areas of road safety expertise.
The Disabled Persons' Assembly offered to contribute expertise in the area of road safety for people with disabilities. The Bikers' Rights Organisation (National) was not prepared to make a contribution to the strategy in its present form, as it did not believe that a strategy without education as its main platform would be effective.
Other key matters to resolve
Other key matters to resolve included funding issues, compatibility of the proposed Strategy with other government policies, and the need for policies focusing on all road users rather than just motor vehicle users.
Funding
Local Government New Zealand made the point that there were widely differing opinions within the local government sector on the level of funding that should be dedicated to road safety as opposed to other areas of roading expenditure, and on how such funding should be collected. LGNZ recommended that a mix of funding sources be used to fund capital, maintenance and specific safety initiatives. Appropriate funding sources would include: road licensing fees, road user charges, ACC levies, petrol taxes, fines, road tolls and loans. It urged central government to continue to work closely with this sector to develop more sophisticated mechanisms that were fair, pro-active, more responsive to particular local needs, and capable of supporting the objectives in the draft Strategy.
TRAFINZ commented that the 2010 Strategy should support a future National Land Transport Strategy requiring correct pricing signals for all transport options, including consideration of all the externalities (safety and environmental) and congestion pricing. It should also require the justification of any funds diverted to the Crown Account as being required to fund the effects (e.g. health and environmental) of land transport. The 2010 Strategy should be consistent with encouraging reductions in traffic growth. Funding for the necessary "mass action" or generic engineering measures required to progress the Strategy, should be on a simplified bulk-funded basis and not require compliance with the current item-by-item Transfund benefit/cost procedure.
Federated Farmers submitted that changes were needed in the way roads were funded: road controlling authorities needed to be able to borrow for capital works; increased use of private enterprise partnerships was required, as was a complete shift away from rating as a source of roading funding.
Environment Southland expressed concern that resources could be decreased in areas such as its own, with a lower road safety risk. It also queried the statement that "in general, urban environments tend to be safer than rural", pointing out that the South Island had a low crash risk as well as significant rural networks. It also commented that, while education would undoubtedly play a role in implementing interventions, there seemed to be no recognition given in the strategy document to the need to formalise the role education would play. Central government should prepare and implement an integrated strategy for improving road users' and the general public's skill and knowledge base.
The Hastings District Council had real concern for road users about the use of B/C ratios as they needed fatal accidents to occur before enough benefits could be accrued to get major safety projects off the ground. It considered that a lower B/C cut-off was needed to make funding available for strategic routes. There were also other considerations besides what was currently used to obtain the B/C ratios to meet the cut-off level and these should be allowed for in safety issues.
The Christchurch Co-ordinating Committee for Traffic Safety suggested that benefit/cost ratios should relate to strategic issues as well as particular sites, so that risky environments could be identified before there were crashes. Global benefit/cost ratios should be identified for different situations.
The Hutt City Council was not confident that heavy vehicle operators were meeting their full share of road costs, particularly for the maintenance of minor roads.
Beca Carter submitted that the main issues were: engineering implementation time and problems with resource consents, resourcing, the public and political will to pay, by-passing the reactive B/C ratio, and allocating more resources to regional councils if they were to be accountable.
Compatibility with other government policies
Many submissions commented on the need to co-ordinate the 2010 Strategy with other government strategies currently under development or proposed.
TRAFINZ submitted that the Government should, during the process of developing its new National Transport Strategy, Energy Efficiency and Conservation Strategy and other transport policy initiatives, acknowledge the linkage between the proposed Road Safety Strategy 2010 and these transport-related strategies, and the potential of those other strategies to have a positive effect on safety outcomes. They also commented that the Strategy should support the Government's encouragement of greater use of passenger transport. The safety benefits of given levels of mode shift should be noted in the final Strategy, and be seen as a legitimate means of achieving reduced social costs. There would clearly be significant safety benefits if traffic growth was reduced.
Local Government New Zealand commented that implementation of the strategy could not take place in isolation from other work being undertaken within the government sector, for example the Land Transport Strategy, the Police Safety Strategy and reforms to encourage passenger transport. Environment Canterbury also sought greater policy integration with the encouragement of sustainable transport modes.
One submission suggested that any strategy adopted should relate to New Zealand's overseas deficit, and to the need to restrict CO2 emissions, as well as the costs of enforcement, engineering and crashes. IPENZ also submitted that the strategy had not recognised the impact of climate change, or the policy challenges of reducing CO2 emissions over the next 10 years.
Auckland Healthcare Services asked for Health Impact Assessments to be completed for all major roading and land transport developments. They also recommended that there be designated transport routes for potentially hazardous materials, and that alternative fuels and additives be assessed for health risks before being introduced.
The AA Driver Education Foundation recommended more research into the causes of crashes, and a link in the Strategy to energy efficiency and environmental benefits. It suggested a co-ordinated and structured programme between government departments to achieve this. The Hamilton City Council also wanted energy-use and health strategies to be taken into account.
The Dunedin City Council considered that there had been little co-ordination between the strategy process and the MoT's roading policy. It recommended a more holistic approach. with safety as a key outcome as it was concerned about unnecessary duplication.
Federated Farmers were concerned that the value of life used in the strategy should be related to interventions seeking to reduce death and injury from other causes. They believed there was a risk that money would be diverted towards road safety and away from other initiatives that had the potential to save more lives.
OSH drew attention to the doubt that existed about whether the Health and Safety in Employment Act fully covered people when they were mobile in the course of their work (for example, taxis, couriers). There was a proposal to amend the Act to eliminate this doubt, in which case Police officers might have to act as HSE inspectors as well.
The Ministry of Health's Public Health Directorate would like to work with the NRSC on the linkages between the 2010 strategy and the Ministry's objective of promoting physical activity in the general population. The Otaki Cycling Environment and Access Network suggested that social cost should include environmental damage and the health costs of a sedentary lifestyle.
The New Zealand Contractors' Federation recommended that safety targets and consequential engineering improvements be linked to the development of an overall road transport strategy.
Focus on all road users
The Bicycle Industry Association of New Zealand commented that cycling received insufficient recognition in the strategy, and that New Zealand was behind most western countries in developing policies and allocating resources to encourage cycling. It also pointed out that transport authorities tended to discourage cycling, to make it 'safer', and that this approach was inequitable and unsustainable. The New Zealand Cycling Strategy Foundation Project commented that safety and engineering were ill defined in the strategy, and that a narrow range of costs and benefits had been considered. It could not comprehend how saving time could be related to safety.
Environment Canterbury wanted a long-term strategy to recognise the wider community benefits from cycling, walking and public transport use. The National Pedestrian Project asked for clarification of the context in which pedestrian safety would be addressed. It was anxious to see access-related targets so that any reductions in pedestrian crashes were not the result of a decrease in walking activity, and would like to see pedestrian interventions based on international best practice. It would also like to see pedestrians better represented within the national road safety consultative groups, and suggested that the LTSA could convene a consultative pedestrian stakeholder group to oversee the setting of appropriate pedestrian targets and research into international best practice with regard to pedestrian initiatives.
The Disabled Persons' Assembly (DPA) commented that people with disabilities were invisible in the strategy. These people are a significant segment of the road-using public and are not covered by general data, so their needs are not adequately addressed. All forms of transport, including the infrastructure in local communities and nationally, should be accessible to people with disabilities, and appropriate planning and design must be provided. The DPA recommended that the LTSA involve people with disabilities, with informed expertise and experience, in the planning and development of the Road Safety Strategy and any subsequent consultation.
The Tauranga District Council asked that the legislation covering use of the road corridors by services such as telecommunications, gas and electricity be reviewed, to give road controlling authorities the final say in the position of poles or other plant on the roadside. It also recommended that the Resource Management Act be amended to give road safety recognition as something to which "particular regard" shall be given so that designations and consents for road safety projects would be more easily obtained.
Page created: 13 September 2002